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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. Nos. 56 & 58
Regular Panel Decision
May 21, 2020

Matter of Seawright v. Board of Elections / Matter of Hawatmeh v. State Board of Elections

The New York Court of Appeals addressed two consolidated cases, *Matter of Seawright* and *Matter of Hawatmeh*, to resolve a departmental split regarding the interpretation of Election Law filing deadlines during the COVID-19 pandemic. In *Seawright*, the Appellate Division, First Department, had excused a candidate's belated filing of a cover sheet and certificate of acceptance due to COVID-19 related illness and quarantine, deeming it not a fatal defect. Conversely, in *Hawatmeh*, the Appellate Division, Third Department, found a candidate's late filing of a certificate of acceptance to be a fatal defect despite pandemic circumstances. The Court of Appeals reversed the *Seawright* decision and affirmed the *Hawatmeh* decision, holding that Election Law § 1-106 (2) mandates strict compliance with filing deadlines. The Court concluded that the failure to timely file constitutes a fatal defect that courts cannot excuse, even under unique or extenuating circumstances like the COVID-19 pandemic, emphasizing that it is the legislature's role to fashion exceptions to the law. Dissenting judges argued for a more flexible interpretation based on legislative intent behind pandemic-related laws and prior Election Law reforms, allowing for substantial compliance during the unprecedented health crisis.

Election LawCOVID-19 PandemicFiling DeadlinesFatal DefectStrict ComplianceBallot AccessJudicial DiscretionLegislative IntentAppellate Division ConflictQuarantine Requirements
References
39
Case No. 535536
Regular Panel Decision
Jul 20, 2023

Matter of Matthews v. New York City Tr. Auth.

Claimant, a train conductor for the New York City Transit Authority, filed for workers' compensation benefits, alleging that his high-risk exposure to COVID-19 and an unsafe work environment exacerbated his pre-existing anxiety and psychiatric conditions. He reported experiencing significant anxiety, depression, and fear due to the pandemic, including a perceived lack of adequate personal protective equipment, mandatory quarantine after exposure, and co-worker deaths. The Workers' Compensation Law Judge and the Workers' Compensation Board disallowed the claim, finding that the stress claimant experienced was not greater than that of other similarly situated workers during the pandemic. The Appellate Division affirmed the Board's decision, concluding that substantial evidence supported the finding that claimant's fear of contracting COVID-19 and his work environment did not result in stress greater than that experienced by other train operators, and therefore, it was not compensable.

Workers' CompensationMental InjuryCOVID-19 ExposureAnxiety ExacerbationPre-existing Psychiatric ConditionsWork-Related StressSimilarly Situated WorkersTrain ConductorAppellate ReviewSubstantial Evidence
References
16
Case No. 13-23-00269-CV
Regular Panel Decision
Mar 13, 2025

Esmeralda Gonzalez v. CS Auto, LTD and Loco Management Company, L.L.C.

Esmeralda Gonzalez sued CS Auto, LTD and LoCo Management Company, L.L.C. (South Texas Buick GMC) for the wrongful death of Leonzo Gonzalez, who contracted COVID-19 while employed by them. Esmeralda alleged premises liability, negligent conduct, general negligence, negligence per se, and wrongful death, claiming the company failed to implement safety protocols during the pandemic. The trial court dismissed her claims under the Texas Pandemic Liability Protection Act (PLPA), finding her expert report insufficient to establish causation. On appeal, the Thirteenth District of Texas Court of Appeals affirmed the dismissal, agreeing that the expert report provided only speculative conclusions and failed to offer a factual and scientific basis for the assertion that the employer's actions caused Leonzo's COVID-19 infection and death, thus not satisfying the statutory requirements.

Pandemic Liability Protection Act (PLPA)COVID-19 LiabilityWrongful DeathExpert Report SufficiencyCausation in LawTexas Civil Practice and Remedies CodeEmployer NegligenceWorkplace ExposureMotion to DismissAppellate Review
References
24
Case No. 535536
Regular Panel Decision
Jul 20, 2023

In the Matter of the Claim of Sheldon Matthews

Sheldon Matthews, a train conductor, appealed a decision by the Workers' Compensation Board, which disallowed his claim for benefits. Matthews alleged that his high-risk exposure to coronavirus and an unsafe work environment exacerbated his pre-existing psychiatric conditions, causing anxiety. His treating psychologist, Michelle Dziedzic, and a long-term psychiatrist opined that his conditions were exacerbated by work-related COVID-19 fears and lack of safety measures. However, a Workers' Compensation Law Judge (WCLJ) and subsequently the Board found that the stress experienced by Matthews was not greater than that of similarly situated workers during the pandemic, which is a requirement for compensability of mental injuries arising from work-related stress. The Appellate Division affirmed the Board's decision, concluding that substantial evidence supported the finding that his fear of contracting COVID-19 and his work environment did not result in stress greater than that experienced by other train operators during the pandemic, especially since he did not contract the virus.

AnxietyDepressionPTSDCOVID-19Work-Related StressMental Health InjuryCompensabilityTrain ConductorPersonal Protective EquipmentExacerbated Preexisting Condition
References
20
Case No. 2025 NY Slip Op 06960 No. 16-20
Regular Panel Decision
Dec 16, 2025

Matter of Klosterman v. New York State Dept. of Corr. & Community Supervision

The New York Court of Appeals affirmed the Appellate Division's decision regarding the eligibility for federal pandemic unemployment benefits. The case addressed whether full-time civil service employees, paid an annual salary but not performing optional summer work due to COVID-19, qualified as "totally unemployed" under New York's Labor Law. The Court held that the New York State Department of Labor correctly applied the state's "total unemployment" requirement, finding the claimants ineligible for Pandemic Unemployment Assistance (PUA), Federal Pandemic Unemployment Compensation (FPUC), and Lost Wage Assistance (LWA). It concluded that the state law requirement did not conflict with the CARES Act, as the Act did not displace state eligibility frameworks, and thus, NYSDOL properly charged claimants with overpayments.

Unemployment Insurance LawCARES ActCOVID-19 BenefitsPandemic Unemployment AssistanceNew York Labor LawTotal Unemployment RequirementStatutory InterpretationEligibility for BenefitsPublic Sector EmploymentAppellate Review
References
15
Case No. 535458
Regular Panel Decision
Mar 28, 2024

Matter of Djanuzakov v. Manhattan & Bronx Surface Tr. Operating Auth.

Claimant, a bus driver, filed for workers' compensation benefits due to work-related stress and psychological injuries stemming from COVID-19 exposure, coworker illnesses and deaths, and workplace conditions. His treating clinical psychologist diagnosed major depressive and anxiety disorder, deeming him temporarily totally disabled. The Workers' Compensation Law Judge initially disallowed the claim, finding his work-related stress no greater than that experienced by other similar workers during the pandemic, a decision affirmed by the Workers' Compensation Board. On appeal, the Appellate Division reversed, citing Matter of Anderson v City of Yonkers, and ruled that the Board must apply the same evidentiary standard for psychological injuries from COVID-19 exposure as it does for physical injuries. The case has been remitted to the Board to determine whether the claimant demonstrated specific or elevated risk of COVID-19 exposure in his work environment and a causal connection between the exposure and his alleged injury.

COVID-19Psychological InjuryWorkers' CompensationStress ClaimCausal ConnectionDisparate BurdenAppellate ReviewRemandNew York LawMental Health
References
1
Case No. 535536
Regular Panel Decision
Mar 28, 2024

In the Matter of the Claim of Sheldon Matthews

Claimant Sheldon Matthews, a train conductor, sought workers' compensation benefits for anxiety and exacerbated psychiatric conditions, alleging high COVID-19 exposure risk and insufficient personal protective equipment (PPE) in his workplace. The Workers' Compensation Law Judge (WCLJ) initially found prima facie medical evidence of posttraumatic stress disorder (PTSD) and adjustment disorder but later disallowed the claim, asserting the stress was not unique among workers during the pandemic. The Workers' Compensation Board affirmed this decision. On appeal, the Appellate Division, Third Department, reversed the Board's decision. Citing Matter of Anderson v City of Yonkers, the Court held that the Board improperly applied a disparate burden to claimants seeking benefits for psychological injuries related to COVID-19 exposure compared to those seeking benefits for contracting the virus. The case was remitted to the Board to determine whether the claimant demonstrated a specific COVID-19 exposure or an elevated risk in his work environment, and if a causal connection existed.

COVID-19Workers' CompensationPsychological InjuryAnxietyPTSDAdjustment DisorderWorkplace ExposurePPEAppellate DivisionRemittal
References
1
Case No. ADJ10588071, ADJ9823909
Regular
Feb 02, 2023

LILLIAN LONA vs. THE DISNEYLAND RESORT, DISNEY ANAHEIM

Here's a summary of the case in four sentences for a lawyer: Applicant Lillian Lona sought an extension for her Supplemental Job Displacement Benefit (SJDB) voucher, which expired March 18, 2021, due to COVID-19 restrictions. She argued the pandemic created a legal impossibility preventing her from utilizing the voucher for computer training. The Workers' Compensation Appeals Board (WCAB) found that the unprecedented pandemic circumstances indeed created a legal impossibility excusing timely compliance with the statutory two-year voucher limit. Consequently, the WCAB granted Lona an additional 15 months from the Opinion's service date to use her SJDB voucher.

Supplemental Job Displacement BenefitSJDB voucherLabor Code section 4658.7(f)Executive Order N-33-20COVID-19 pandemicstay-at-home orderlegal impossibilitytollingvocational retrainingcomputer training
References
10
Case No. 535458
Regular Panel Decision
Mar 28, 2024

In the Matter of the Claim of Bolot Djanuzakov

The claimant, a bus driver, sought workers' compensation benefits for work-related stress and psychological injuries due to COVID-19 exposure, coworker deaths, and workplace conditions. A clinical psychologist diagnosed him with major depressive and anxiety disorders, deeming him temporarily totally disabled. The Workers' Compensation Law Judge and Board disallowed the claim, finding his stress not exceeding that of similar workers during the pandemic. The Appellate Division reversed and remitted the matter, citing its decision in *Matter of Anderson v City of Yonkers*, which held that the Board must apply a consistent burden of proof for both physical and psychological injuries stemming from COVID-19 exposure in the workplace, requiring a determination of specific exposure or elevated risk.

COVID-19 ExposurePsychological InjuryWork-Related StressWorkers' Compensation BenefitsAppellate DivisionRemittalMajor Depressive DisorderAnxiety DisorderBus DriverCompensable Injury
References
1
Case No. 2023 NY Slip Op 01123
Regular Panel Decision
Mar 02, 2023

Matter of Kohn v. County of Sullivan

Burt Kohn, an administrator for the Sullivan County Adult Care Center, was terminated following a disciplinary hearing based on charges of misconduct and incompetence. The charges stemmed from allegations that he suggested a subordinate share login credentials for a CDC database and asked staff to volunteer to test positive for COVID-19. The Appellate Division, Third Department, modified the determination by annulling two charges related to 'directing' password sharing, finding only a 'suggestion' was made. However, it sustained charges of misconduct and incompetence for the suggestion itself, noting potential penalties for non-compliance with rules, and upheld charges regarding his inappropriate COVID-19 remarks. The court ultimately affirmed the termination penalty, deeming it proportionate given his role during the pandemic.

Civil Service LawMisconduct ChargesIncompetence ChargesEmployment TerminationDisciplinary ProceedingsSubstantial Evidence ReviewDue ProcessPassword Sharing ProhibitionCOVID-19 ReportingNursing Home Administration
References
5
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